Tax Attorney in Cleveland, OH

Federal IRS representation for Cleveland individuals and businesses — audits, back taxes, liens, levies, Cleveland Clinic 1099 physician and clinical-trial royalty work, Progressive Insurance and KeyBank RSU disputes, Sherwin-Williams and Eaton executive equity, FBAR for Polish, Slovak, Italian, Hungarian, Czech, and Croatian heritage accounts, and U.S. Tax Court litigation at the Howard M. Metzenbaum U.S. Courthouse on Superior Avenue. We coordinate Ohio Department of Taxation matters under Ohio TBOR-1 Declaration of Tax Representative, handle the Cleveland 2.5% municipal income tax (CCA-administered) directly, and refer Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel under a co-counsel arrangement.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: May 25, 2026.

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If you owe back taxes in Cleveland, here is what shapes your 2026 case

Ohio operates a graduated personal income tax with rates from 0% to 3.5% under Ohio Revised Code § 5747.02, the result of a multi-year flat-rate phase-down enacted through Am. Sub. H.B. 33 and subsequent budget bills. Corporate income is taxed indirectly through the 5.75% Commercial Activity Tax (CAT) on gross receipts under R.C. Ch. 5751 — Ohio has no traditional corporate income tax. State sales tax is 5.75% under R.C. § 5739.02, and Cuyahoga County stacks a 2.25% local sales-tax permissive on top under R.C. § 5739.021, bringing the combined Cleveland sales-tax rate to 8.0%. On top of all of that, the City of Cleveland imposes a 2.5% municipal income tax under Cleveland Codified Ordinances Ch. 191, collected on the city's behalf by the Central Collection Agency (CCA) at 205 W St Clair Avenue — one of the highest municipal income tax rates among major Ohio cities, materially higher than Cincinnati's 1.8%.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Ohio Department of Taxation has issued a Notice of Assessment under R.C. § 5747.13, the deadline to act is short. Ohio taxpayers get 60 days from the Final Determination to petition the Ohio Board of Tax Appeals under R.C. Ch. 5717. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and Ohio TBOR-1 with the Ohio Department of Taxation, and put administrative brakes on collection while the case is built.

Federal tax representation for Cleveland taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases — holds regular trial sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE. From our Robertson Boulevard office in Los Angeles, we represent Cleveland residents and Ohio-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Ohio state tax matters — the graduated 0% to 3.5% personal income tax under R.C. § 5747.02, the 5.75% Commercial Activity Tax on gross receipts under R.C. Ch. 5751, the 5.75% state sales tax under R.C. § 5739.02 with the Cuyahoga County 2.25% permissive sales tax under R.C. § 5739.021 (combined 8.0% in Cleveland), withholding-tax assessments, and contested matters headed to the Ohio Board of Tax Appeals — we file Ohio TBOR-1 Declaration of Tax Representative with the Ohio Department of Taxation and handle the administrative track directly. For Cleveland's 2.5% municipal income tax administered by the Central Collection Agency under Cleveland Codified Ordinances Ch. 191, we respond directly to CCA assessment notices and audit requests. For formal litigation in the Ohio Board of Tax Appeals (R.C. Ch. 5717) or the Ohio state courts of common pleas, we associate with locally admitted Ohio counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for Cleveland Clinic physicians, biotech and medical-device executives, and corporate equity holders at Progressive, KeyBank, Sherwin-Williams, and Eaton, stays with us.

Cleveland sits at the center of one of the most economically distinctive metros in the Great Lakes region. The Cleveland Clinic, headquartered on the East Side main campus on Euclid Avenue, ranks as one of the top hospital systems globally and produces an outsized base of 1099 physician engagements, biotech and medical-device RSU and ISO files, and clinical-trial royalty income that flows through IRC § 1235 patent-sale treatment and IRC § 162(a) ordinary-and-necessary deductions. Progressive Insurance, headquartered in Mayfield Village, anchors the U.S. auto-insurance industry with corresponding W-2, RSU, and deferred-compensation issues. KeyBank, headquartered at Key Tower in downtown Cleveland, drives regional banking RSU and ISO work. Sherwin-Williams Company, headquartered downtown in the new Cleveland HQ, leads the global paints and coatings industry with executive equity files. Eaton Corporation, headquartered in suburban Beachwood, generates diversified-industrial RSU. Lincoln Electric in Euclid drives welding-and-manufacturing equity. FirstEnergy in nearby Akron anchors utility-sector work. American Greetings at Crocker Park, Goodyear Tire & Rubber in Akron, and TimkenSteel in Canton add private-company and W-2 files. Case Western Reserve University, Cleveland State, and Baldwin Wallace produce academic appointments under IRC § 117 tuition-reduction rules and Schedule K-1 partnership and grant-income issues. The Cleveland Cavaliers, Browns, Guardians, and Monsters create athlete state-sourcing files under Ohio's 0% to 3.5% personal income tax plus the Cleveland 2.5% municipal layer — an effective combined Ohio-and-municipal rate at the top tier near 6% on Cleveland-sourced wages. Cleveland's Polish, Slovak, Italian, Hungarian, Czech, and Croatian heritage neighborhoods — Slavic Village, Tremont, Lakewood, and Little Italy — bring FinCEN Form 114 (FBAR) and Streamlined Filing Compliance Procedures into nearly every household-finance review where Eastern European deposit accounts or inherited foreign assets are in the mix.

Your tax rights as a Cleveland taxpayer

Three parallel rights frameworks apply when you owe tax in Cleveland. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from Ohio R.C. Title 57 (Taxation) and the Ohio Taxpayers' Bill of Rights at R.C. § 5703.50 through § 5703.56. Municipal rights come from Ohio H.B. 5 (2014) uniform municipal-income-tax provisions codified at R.C. Ch. 718, plus Cleveland's local code at Cleveland Codified Ordinances Ch. 191 as administered by the Central Collection Agency. Knowing all three is the difference between a clean resolution and a missed 60-day Ohio Board of Tax Appeals petition deadline that turns into a state tax lien filed with the Cuyahoga County Court of Common Pleas.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS must deal with us first, not you. Ohio mirrors this through the TBOR-1 Declaration of Tax Representative authorized under R.C. § 5703.05. The CCA accepts a separate written authorization for Cleveland municipal income-tax matters.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The Tax Court holds regular trial sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE.

Right to Ohio Board of Tax Appeals review

R.C. Ch. 5717 gives you 60 days from a Final Determination of the Tax Commissioner to petition the Ohio Board of Tax Appeals, seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. The BTA is an independent quasi-judicial body with statewide jurisdiction over state and county tax appeals. Decisions are reviewable by the Ohio Supreme Court under R.C. § 5717.04. Tighter than the federal 90-day Tax Court deadline — the 60-day window is jurisdictional.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review in the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Ohio operates a parallel Offer-in-Compromise program through the Office of the Attorney General under R.C. § 131.02 for accounts certified to AG collection, with hardship standards similar to the federal program. The CCA accepts municipal-tax payment-plan and hardship submissions on a case-by-case basis under Cleveland's local code.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high, but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Cleveland taxpayers

Offer in Compromise under IRC § 7122

We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For Cleveland taxpayers, a federal OIC does not resolve Ohio state liability; we run a parallel Ohio compromise through the Office of the Attorney General under R.C. § 131.02 where the state debt has been certified to AG collection, and we address Cleveland municipal balances with the CCA on a separate track.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — an under-used resolution path for Cleveland taxpayers between $50,000 and $250,000 in federal debt. Ohio runs its own state Payment Plan program through OH|TAX eServices, and the CCA accepts Cleveland municipal payment plans directly.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Cleveland property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Cuyahoga County Recorder encumber title; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing on a Tremont, Ohio City, Shaker Heights, Cleveland Heights, Lakewood, or Beachwood transaction.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. Ohio state tax liens follow a parallel track under R.C. § 5747.13 and R.C. Ch. 131, certified to the Ohio Attorney General for collection and recorded in the Cuyahoga County Court of Common Pleas.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like Cleveland Clinic 1099 physician sourcing, clinical-trial royalty income under IRC § 1235, cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR) for Polish, Slovak, Italian, Hungarian, Czech, and Croatian bank accounts, S-corporation reasonable-compensation, Progressive and KeyBank RSU and ISO disposition timing, and IRC § 83(b) election validation. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Cleveland trial sessions are held at the Metzenbaum Courthouse.

Penalty abatement under IRC § 6651 and IRM 20.1.1

First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Ohio penalties under R.C. § 5747.15 and Cleveland municipal penalties under Cleveland Codified Ordinances Ch. 191 follow a separate reasonable-cause analysis.

Twelve types of Cleveland tax matters we handle

Federal cases for Cleveland residents and businesses, framed against the Ohio Department of Taxation overlay and the Cleveland 2.5% municipal income tax where it matters.

Cleveland Clinic 1099 physician and clinical-trial royalty work

The Cleveland Clinic main campus on Euclid Avenue is one of the top hospital systems globally. Staff and visiting physicians work under a mix of W-2 employment and 1099 independent-contractor arrangements; clinical-trial principal investigators receive royalty and milestone payments tied to medical-device and biotech patents. We work IRC § 1235 patent-sale capital-gain treatment, IRC § 162(a) ordinary-and-necessary deductions for CME, malpractice, and home-office, IRC § 199A qualified-business-income on the 1099 side, and Schedule SE self-employment-tax calculations. The federal-plus-Ohio-plus-Cleveland combined effective rate on physician income at the top tier reaches 43% (37% federal + 3.5% Ohio + 2.5% Cleveland).

Progressive, KeyBank, and Sherwin-Williams RSU and ISO disputes

Progressive Insurance (Mayfield Village), KeyBank (Key Tower downtown), Sherwin-Williams (downtown HQ), and Eaton Corporation (Beachwood) are the dominant equity-compensation drivers in the metro. RSU vesting under IRC § 83 generates ordinary-income W-2 inclusion at vest with a forced supplemental-wage withholding of 22% (or 37% above $1 million in aggregate). ISO disqualifying-disposition events under IRC § 422, AMT bargain-element inclusion under IRC § 56, and IRC § 83(b) election timing on restricted-stock grants drive the executive case mix. Add Ohio's 3.5% top bracket plus Cleveland's 2.5% municipal income tax, and a $500,000 RSU vesting event arrives in April with six-figure shortfalls against the 37% top bracket.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Cleveland restaurant, hospitality, construction, trucking, and Rust Belt manufacturing owners are the most frequent targets. The IRS uses Form 4180 interviews to identify responsible persons. Ohio pursues a parallel responsible-officer claim under R.C. § 5739.33 for unpaid sales-tax trust funds and R.C. § 5747.07 for income-tax withholding.

Cleveland 2.5% municipal income tax via CCA

Cleveland imposes a 2.5% municipal income tax under Cleveland Codified Ordinances Ch. 191, collected on the city's behalf by the Central Collection Agency at 205 W St Clair Avenue. That rate is materially higher than Cincinnati's 1.8% or Columbus's 2.5% baseline, and it stacks on top of Ohio's 0% to 3.5% state PIT. Cleveland-resident taxpayers also owe municipal income tax on income earned outside the city, with a credit for taxes paid to other municipalities under R.C. Ch. 718. CCA notices of assessment carry a 60-day protest window; we respond on letterhead with Form 2848 layered on the federal side and a separate written CCA authorization.

Notice of Federal Tax Lien

NFTLs filed with the Cuyahoga County Recorder (or the Lake, Geauga, Lorain, Medina, or Summit County recorders for suburban Cleveland) encumber title and trigger CDP rights under IRC § 6320. A parallel Ohio state tax lien may be filed by the Ohio Attorney General under R.C. Ch. 131 with the Cuyahoga County Court of Common Pleas, where it operates as a judgment lien against the taxpayer's real and personal property.

IRS bank or wage levy

Bank levies on accounts held at KeyBank, Huntington National Bank, PNC, Fifth Third, Citizens, Chase, or any Ohio-chartered institution. Wage levies hit Cleveland employers within days of CP90 or LT11 issuance — we move on Form 12153 CDP requests and Form 433-F hardship submissions concurrently.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. Cleveland Hopkins International serves a large Polish, Slovak, Italian, Hungarian, Czech, and Croatian heritage population with regular travel to family abroad; passport revocation hits these communities hard. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure — Eastern European accounts

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Cleveland's Polish, Slovak, Italian, Hungarian, Czech, and Croatian heritage communities — concentrated in Slavic Village, Tremont, Lakewood, Parma, and Little Italy — carry a meaningful share of inherited and continuing accounts at PKO Bank Polski, Slovenska Sporitelna, UniCredit, OTP Bank, Česka sporitelna, ZagrebaČka Banka, and similar institutions. Streamlined Filing Compliance Procedures are a frequent engagement; willful-failure penalties can reach the greater of $100,000 or 50% of account balances under 31 U.S.C. § 5321(a)(5).

Cavaliers, Browns, Guardians, and Monsters athlete payroll

Cleveland rosters cover four major-league franchises: the Cavaliers (NBA, Rocket Mortgage FieldHouse), the Browns (NFL, FirstEnergy Stadium), the Guardians (MLB, Progressive Field), and the Monsters (AHL). Athlete state-sourcing under the so-called “jock tax” allocates wage and bonus income to each state in which a game is played, requiring multi-state filing and IRC § 901 foreign-tax-credit-style analysis at the state level. Ohio applies a parallel duty-day analysis under R.C. § 5747.05 for non-resident athletes playing in Cleveland, and Cleveland's 2.5% municipal income tax applies to visiting-team Cleveland-sourced game-day income under R.C. Ch. 718.

Innocent Spouse Relief

IRC § 6015 relief for spouses jointly liable on a return where the other spouse's items caused the deficiency. We file Form 8857 with a clean factual record — common in divorces involving Cleveland Clinic physician spouses whose 1099 income, clinical-trial royalty payments, and 83(b) election decisions the other spouse never saw.

Rust Belt manufacturing Schedule C and payroll TFRP

Cleveland's steel, rubber, welding, and heavy-manufacturing heritage — Cleveland-Cliffs (iron ore and steel), Lincoln Electric, Goodyear and Firestone (Akron rubber), TimkenSteel (Canton) — produces a long tail of family-owned fabrication shops, machine shops, and tier-2 supplier S-corps. Schedule C / Schedule K-1 reporting, Form 941 payroll-tax delinquencies, and IRC § 6672 Trust Fund Recovery Penalty exposure are routine for the smaller-shop owner. Environmental cleanup tax credits under IRC § 38 are also in the mix for Cuyahoga River and Lake Erie post-1969-fire remediation projects.

Unfiled returns and SFR substitutes

When the IRS files a Substitute for Return under IRC § 6020(b), the assessed tax is almost always overstated. Filing the correct original return is the first move — it routinely reduces the balance. Ohio runs a parallel substitute-return process under R.C. § 5747.13, and the Department uses federal return matching to issue a Notice of Assessment whenever a federal SFR posts. The CCA also pursues unfiled Cleveland municipal returns, with non-filer assessments based on W-2 wage data shared by the Ohio Department of Taxation.

Nine common causes of tax debt for Cleveland taxpayers

Patterns we see repeatedly in Cleveland-based engagements. None of them are unusual — all of them are resolvable.

1. Cleveland Clinic 1099 physician under-withholding

A staff or visiting physician earns six figures on a 1099 contract with no estimated-tax payments, then discovers the next April that federal self-employment tax (15.3% under IRC § 1401) stacks on top of the 37% federal bracket, 3.5% Ohio bracket, and 2.5% Cleveland municipal rate. The CP14 lands in May, the Ohio Notice of Assessment follows, and the CCA delinquency notice arrives within months.

2. Corporate RSU and ISO under-withholding

A Progressive, KeyBank, Sherwin-Williams, Eaton, or Lincoln Electric RSU vests; the employer withholds 22% federal supplemental, leaving a six-figure shortfall against the 37% top bracket. Add 3.5% Ohio and 2.5% Cleveland, and a $500,000 vesting event arrives in April with $75,000 to $100,000 still owed. The CP14 lands in May, the Ohio Notice of Assessment follows within 90 days.

3. Business closure

When an LLC or S-corp closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Ohio pursues a parallel responsible-officer claim under R.C. § 5747.07 for income-tax withholding and R.C. § 5739.33 for trust-fund sales tax.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted. Cuyahoga County divorce filings track the federal record, and unresolved RSU, ISO, or clinical-trial royalty income from a Cleveland Clinic, Progressive, or KeyBank spouse is a recurring driver.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. The Ohio Department of Taxation runs a parallel identity-theft unit, and the CCA cross-checks with the Department on suspicious filings.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price. Cleveland has a meaningful retail crypto population in the downtown finance corridor and University Circle research clusters.

7. Late-filed or unfiled returns

Failure-to-file under IRC § 6651(a)(1) compounds at 5% per month, capped at 25%. After three years, refunds are barred under IRC § 6511. Ohio imposes a parallel late-filing penalty under R.C. § 5747.15. The CCA pursues unfiled Cleveland returns separately under Cleveland Codified Ordinances Ch. 191.

8. Real-estate sale without estimated tax

A Tremont, Ohio City, Shaker Heights, Cleveland Heights, Lakewood, or Beachwood property sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules of IRC § 1221.

9. Ohio Use Tax on out-of-state purchases

R.C. § 5741.02 imposes a 5.75% state Use Tax (plus the 2.25% Cuyahoga County permissive, combined 8.0%) on goods purchased out of state and used in Ohio. The Department of Taxation enforces aggressively through vehicle-registration cross-matching and out-of-state retailer reporting; many Cleveland taxpayers discover the liability years late when a boat, RV, or aircraft registration triggers the match.

Eight tax liabilities that pull in Cleveland taxpayers

Federal authority alongside the Ohio statute where there is a parallel.

Failure to file federal return

IRC § 6651(a)(1) imposes 5%/month, max 25%, plus interest under IRC § 6601. The Ohio mirror is R.C. § 5747.15, with separate late-filing and late-payment exposure on the same balance.

Failure to file Ohio state return

R.C. § 5747.15 imposes a late-filing penalty separate from the federal penalty. The Ohio Department of Taxation may issue a Notice of Assessment under R.C. § 5747.13, triggering a 60-day protest window and, if the protest fails, a Final Determination opening the 60-day Ohio Board of Tax Appeals petition deadline under R.C. Ch. 5717.

Failure to file Cleveland municipal return

Cleveland Codified Ordinances Ch. 191 requires every Cleveland resident and non-resident earning Cleveland-sourced income to file an annual municipal return with the Central Collection Agency. Failure-to-file penalties are calculated under R.C. Ch. 718 uniform municipal-income-tax rules; the CCA pursues collection through judicial proceedings in the Cuyahoga County Municipal Court or Court of Common Pleas.

Federal § 7122 Offer in Compromise eligibility

All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.

Ohio sales tax delinquency

R.C. § 5739.02 imposes a 5.75% state sales tax; R.C. § 5739.021 authorizes a Cuyahoga County 2.25% permissive sales tax on top, combined 8.0% in Cleveland. Personal liability for responsible persons under R.C. § 5739.33 pierces the corporate veil for trust-fund sales tax. The Ohio Department uses the vendor's license revocation as an enforcement lever — pulling a restaurant's license effectively closes the business.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Ohio applies a similar responsible-person rule to withheld state income tax under R.C. § 5747.07 and to sales tax under R.C. § 5739.33.

Accuracy-related penalty

IRC § 6662 imposes 20% on substantial-understatement or negligence; IRC § 6663 imposes 75% on fraud. Defense is built on substantial authority, adequate disclosure, or reasonable cause.

Ohio Commercial Activity Tax (CAT)

R.C. Ch. 5751 imposes a 5.75% Commercial Activity Tax on gross receipts over the bright-line nexus and exclusion thresholds. Ohio has no traditional corporate income tax; CAT operates as the corporate-level levy on substantial Ohio receipts. CAT registration, quarterly returns, and Annual Minimum Tax obligations apply to every business with Ohio receipts above the threshold — including out-of-state e-commerce sellers shipping into Cleveland.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Cuyahoga County Recorder.

Sample tax-resolution outcomes

Anonymized client matters drawn from our $91M+ aggregate tax-relief record across 2,000+ resolved cases.

Year	Tax debt	Resolution	Final outcome
2024	$162,388	IRC § 6159 Installment Agreement	Accepted at $25/month, partial-pay
2024	$138,750	Streamlined Installment Agreement	Accepted at $25/month
2023	$129,475	Partial-Pay Installment Agreement	Accepted at $50/month
2023	$117,620	IRC § 6159 Installment Agreement	Accepted at $25/month
2022	$108,440	Partial-Pay Installment Agreement	Accepted at $50/month

Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service, the Ohio Department of Taxation, the Central Collection Agency, and the Ohio Board of Tax Appeals.

Why Victory Tax Lawyers for a Cleveland federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Ohio-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE. IRS administrative practice runs on Form 2848 Power of Attorney, which is accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Cleveland clients never need a separately admitted Ohio attorney because the case is, at its core, federal.

For administrative work before the Ohio Department of Taxation — protests, audit responses, Notice of Assessment replies, Final Determination protests, and Payment Plan requests — we file Ohio TBOR-1 Declaration of Tax Representative under R.C. § 5703.05 and handle the matter remotely. For Cleveland's 2.5% municipal income tax assessed by the Central Collection Agency, we file a CCA written authorization and respond directly on letterhead. When a case must move to the Ohio Board of Tax Appeals (R.C. Ch. 5717) at 30 East Broad Street in Columbus, or to a court of common pleas in Cuyahoga County, we coordinate with locally admitted Ohio counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for Cleveland Clinic physicians and Progressive, KeyBank, Sherwin-Williams, and Eaton equity holders, stays with us.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $91M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being an Ohio-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Cleveland taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to drive to Robertson Boulevard.

Our seven-step process for Cleveland clients

Free consultation

A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.

Engagement letter

A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.

Form 2848, TBOR-1, and CCA POA

We file the federal Power of Attorney with the IRS, Ohio TBOR-1 with the Department of Taxation, and a written authorization with the CCA for Cleveland municipal matters.

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or a Board of Tax Appeals petition through local counsel — and handle every IRS, Ohio Department, and CCA contact.

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Two collection clocks: federal CSED and Ohio's certified-debt rule

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more.

Ohio runs a parallel state collection rule. Under R.C. § 5747.13, the Ohio Department of Taxation must issue a Notice of Assessment within four years of the return's due date (no limit for fraud or unfiled returns). Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may file a judgment lien with the Cuyahoga County Court of Common Pleas. Ohio income-tax judgment liens are governed by the dormancy and revival rules of R.C. § 2329.07 and may be revived for additional periods. The Cleveland municipal income tax, administered by the Central Collection Agency under Cleveland Codified Ordinances Ch. 191 and R.C. Ch. 718, follows a separate collection timeline and is enforced through the Cuyahoga County Municipal Court. Many Cleveland taxpayers carry a federal CSED, an Ohio AG judgment, and a CCA municipal balance simultaneously — pull all three records and know all three dates before agreeing to any payment plan or amended return that could restart a clock.

Cleveland tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices in metro Cleveland is what separates an answered Notice from a wage levy or judgment lien. Below is the working list our firm uses on every Cleveland matter.

Internal Revenue Service — Cleveland TAC

The federal tax authority, at irs.gov. The Cleveland Taxpayer Assistance Center operates at 1240 E 9th Street, Suite 350, Cleveland OH 44199, inside the Anthony J. Celebrezze Federal Building. Appointments required.

U.S. Tax Court — Cleveland trial sessions

The U.S. Tax Court holds regular trial sessions in Cleveland at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Ohio Department of Taxation

The state tax authority, at tax.ohio.gov. Headquartered at 4485 Northland Ridge Boulevard, Columbus OH 43229, with a Cleveland field office for in-person taxpayer service. Administers the 0% to 3.5% graduated personal income tax under R.C. § 5747.02, the 5.75% Commercial Activity Tax on gross receipts under R.C. Ch. 5751, the 5.75% state sales tax under R.C. § 5739.02, the Use Tax under R.C. § 5741.02, and the school-district income tax under R.C. Ch. 5748.

Ohio Board of Tax Appeals

An independent quasi-judicial body with statewide jurisdiction over Ohio Department of Taxation final determinations, county Board of Revision property-tax appeals, and municipal income-tax disputes after exhaustion of local remedies. Seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. 60-day petition deadline from the Final Determination under R.C. Ch. 5717. Decisions are reviewable by the Ohio Supreme Court under R.C. § 5717.04. Victory Tax Lawyers refers Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel; we handle the federal portion and Ohio Department administrative work directly under TBOR-1.

Cuyahoga County Treasurer

The county tax-collection authority for Cleveland. Office at 2079 E 9th Street, 3rd Floor, Cleveland OH 44115. Page: cuyahogacounty.gov/treasurer. Administers Cuyahoga County property-tax billing and collection.

Cuyahoga County Fiscal Officer / Assessor

The county assessment authority. Office at 2079 E 9th Street, 4th Floor, Cleveland OH 44115. Sets the assessed value of Cleveland property — the starting point for the county tax bill. Appeals run through the Cuyahoga County Board of Revision, with further review at the Ohio Board of Tax Appeals under R.C. Ch. 5717.

City of Cleveland Department of Finance & CCA

The municipal finance authority at 601 Lakeside Avenue, Room 502, Cleveland OH 44114. Cleveland's 2.5% municipal income tax under Cleveland Codified Ordinances Ch. 191 is collected by the Central Collection Agency (CCA) at 205 W St Clair Avenue, Cleveland OH 44113 — a multi-municipality collection cooperative administering Cleveland and dozens of other Northeast Ohio cities. CCA notices carry a 60-day protest window under R.C. Ch. 718.

U.S. District Court — Northern District of Ohio, Cleveland Division

Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court (N.D. Ohio, Cleveland Division, Carl B. Stokes U.S. Courthouse, 801 W Superior Avenue, Cleveland OH 44113) or the U.S. Court of Federal Claims in Washington, D.C.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Cleveland cases run through the Appeals offices serving the Great Lakes region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Cleveland

An independent organization within the IRS that helps when normal channels stall. The Cleveland TAS office serves taxpayers across Northeast Ohio. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Cleveland matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, an Ohio Department Final Determination, or a CCA municipal-income-tax assessment is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Cleveland tax

Does Ohio have a state income tax?

Yes. Ohio operates a graduated personal income tax with rates from 0% to 3.5% under R.C. § 5747.02 — the result of a multi-year phase-down enacted through Am. Sub. H.B. 33 and subsequent budget bills. Ohio has no traditional corporate income tax; instead, corporate-level taxation runs through the 5.75% Commercial Activity Tax on gross receipts under R.C. Ch. 5751. State sales tax is 5.75% under R.C. § 5739.02 with a Cuyahoga County permissive 2.25% under R.C. § 5739.021, producing a combined 8.0% sales-tax rate in Cleveland. On top of all that, the City of Cleveland imposes a 2.5% municipal income tax under Cleveland Codified Ordinances Ch. 191, collected by the Central Collection Agency — materially higher than Cincinnati's 1.8%. Ohio repealed its estate tax effective January 1, 2013; estate-tax exposure for Ohio residents is federal-only.

Where is the closest U.S. Tax Court trial location to Cleveland?

The U.S. Tax Court holds regular trial sessions in Cleveland itself at the Howard M. Metzenbaum U.S. Courthouse, 201 Superior Avenue NE. A taxpayer anywhere in Northeast Ohio can request the Cleveland trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

What is the Ohio Board of Tax Appeals and how does it work?

The Ohio Board of Tax Appeals is an independent quasi-judicial body with statewide jurisdiction over Ohio Department of Taxation final determinations, county Board of Revision property-tax decisions, and municipal income-tax disputes after exhaustion of local remedies. It is seated at 30 East Broad Street, 24th Floor, Columbus OH 43215. The petition deadline is 60 days from the Tax Commissioner's Final Determination under R.C. Ch. 5717 — tighter than the federal 90-day Tax Court deadline. Decisions are reviewable directly by the Ohio Supreme Court under R.C. § 5717.04. Victory Tax Lawyers refers Ohio Board of Tax Appeals litigation to locally admitted Ohio counsel; we handle the federal portion and Ohio Department administrative work directly under Ohio TBOR-1.

What is Ohio's collection statute of limitations?

R.C. § 5747.13 gives the Ohio Department of Taxation four years from a return's due date to issue a Notice of Assessment (no limit for fraud or unfiled returns). Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may file a judgment lien with the county court of common pleas. Ohio income-tax judgment liens are governed by the dormancy and revival rules of R.C. § 2329.07. The federal CSED under IRC § 6502 is 10 years and is not renewable — meaning Ohio judgment liens, if periodically revived, can outlive the federal collection clock. Pulling all records is the first step before agreeing to any payment plan that might restart a clock.

I am a Cleveland Clinic physician on a 1099 contract — what tax issues should I worry about?

Four things sit on top of every Cleveland Clinic 1099 physician file we open. First, self-employment tax under IRC § 1401 stacks 15.3% on the first $168,600 of net earnings (2024 wage base, indexed annually) and 2.9% Medicare with no cap on top — before federal income tax even applies. Second, clinical-trial royalty income flowing from medical-device or biotech patents may qualify for IRC § 1235 capital-gain treatment if structured as a transfer of substantially all rights, but the IRS scrutinizes the contract closely. Third, IRC § 162(a) ordinary-and-necessary deductions for CME, professional liability insurance, board-certification fees, white-coat and scrubs costs, and a home-office deduction under IRC § 280A all require contemporaneous records. Fourth, IRC § 199A qualified-business-income deduction phases out for specified-service-trade-or-business (medical practice) at the top of the income range, but planning opportunities remain. The federal-plus-Ohio-plus-Cleveland combined effective rate on top-tier physician income reaches 43%.

Can I be audited by both the IRS and the Ohio Department for the same year?

Yes. The IRS and the Ohio Department of Taxation operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Ohio under the state's federal-change reporting rule (R.C. § 5747.10), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Ohio return. Because Ohio maintains a 0% to 3.5% graduated rate plus the Cleveland 2.5% municipal layer collected by the CCA, a federal adjustment now produces a predictable state and municipal follow-on calculation.

Does Ohio offer an Offer in Compromise equivalent to the federal program?

Ohio handles state-tax compromises differently from many states. Once an Ohio income-tax debt is certified to the Office of the Attorney General under R.C. § 131.02, the AG's Collections Enforcement Section may consider a compromise offer based on doubt as to collectibility or financial hardship. Hardship standards mirror the federal framework, but documentation requirements are tighter and the AG generally insists on full disclosure of household finances and asset values. We typically run an Ohio AG compromise in parallel with the federal Offer where both debts are real. The Central Collection Agency, which collects the Cleveland 2.5% municipal income tax, accepts payment-plan and hardship submissions on a case-by-case basis under Cleveland's local code.

How does Cleveland's 2.5% municipal income tax compare to other Ohio cities?

Cleveland's 2.5% rate is one of the highest municipal income tax rates among major Ohio cities. By comparison, Cincinnati sits at 1.8%, Columbus at 2.5%, Toledo at 2.5%, Akron at 2.5%, and Dayton at 2.5%. The structure is governed by the uniform municipal income tax provisions in R.C. Ch. 718 (Ohio H.B. 5 of 2014) and Cleveland's local code at Cleveland Codified Ordinances Ch. 191. Cleveland-resident taxpayers also owe municipal income tax on income earned outside the city, with a credit for taxes paid to other municipalities. The Central Collection Agency (CCA), a multi-municipality cooperative at 205 W St Clair Avenue, collects Cleveland's tax along with dozens of other Northeast Ohio cities. CCA notices carry a 60-day protest window.

I have a Polish, Slovak, Italian, Hungarian, Czech, or Croatian bank account — do I have to report it?

Yes, if the aggregate value of all foreign financial accounts you own or have signature authority over exceeded $10,000 at any point during the calendar year. FinCEN Form 114 (FBAR) is due April 15 with an automatic extension to October 15. Non-willful failure to file carries up to a $10,000 civil penalty per violation; willful failure can reach the greater of $100,000 or 50% of account balances under 31 U.S.C. § 5321(a)(5). The IRS Streamlined Filing Compliance Procedures — both Domestic and Foreign — offer a path to bring accounts at PKO Bank Polski, Bank Pekao, Slovenska Sporitelna, VÚB Banka, UniCredit, OTP Bank, Česka Sporitelna, ZagrebaČka Banka, and similar Eastern European institutions into compliance with substantially reduced penalty exposure. Cleveland's Polish, Slovak, Italian, Hungarian, Czech, and Croatian heritage communities — concentrated in Slavic Village, Tremont, Lakewood, Parma, and Little Italy — make this a frequent engagement, particularly where inherited accounts have gone unreported for years.

Can a California-Bar-admitted attorney represent me in Cleveland?

For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Cleveland. For Ohio Department of Taxation administrative work, we file Ohio TBOR-1 Declaration of Tax Representative and handle the matter remotely. For the Cleveland 2.5% municipal income tax administered by the CCA, we file a written authorization with the agency. For formal litigation in the Ohio Board of Tax Appeals or an Ohio state court, we co-counsel with locally admitted Ohio attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Ohio follows a parallel filing-compliance posture; the Department may issue a Notice of Assessment under R.C. § 5747.13 when a taxpayer fails to file, and the CCA pursues unfiled Cleveland returns separately.

Can the IRS or the Ohio Department levy my Cleveland bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at KeyBank, Huntington National Bank, PNC, Fifth Third, Citizens, Chase, or any Ohio-chartered institution and serve wage levies on Cleveland employers. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1). The Ohio Department, after certification to the Attorney General under R.C. § 131.02, may file a judgment lien and pursue garnishments through the Cuyahoga County Court of Common Pleas.

I am a Cavaliers, Browns, Guardians, or Monsters player — what tax issues should I expect?

Professional athletes resident in Cleveland pay federal income tax (up to 37%), Ohio income tax (0% to 3.5% graduated), Cleveland municipal income tax (2.5%), and self-employment-style FICA depending on whether the contract treats them as W-2 employees or independent contractors. Multi-state “jock tax” allocation requires filing returns in every state where games are played, with day-counts driving wage sourcing. The IRS audits athlete returns for endorsement-income sourcing, training-camp residency claims, and entity-structure questions around image-rights LLCs. Ohio applies a parallel duty-day analysis under R.C. § 5747.05 for non-resident athletes playing in Cleveland, and the city's 2.5% municipal income tax applies to visiting-team Cleveland-sourced game-day income under R.C. Ch. 718. The combined Ohio-plus-Cleveland effective rate on top-tier athlete income reaches roughly 6% on Cleveland-sourced wages.

How long does a federal Offer in Compromise take to process?

An IRS Offer in Compromise typically takes six to twelve months from filing to a final decision. The IRS deems an Offer accepted if not rejected within 24 months under IRC § 7122(f). While the OIC is pending, IRC § 6331(k) bars most levies, and the CSED is tolled. Rejected offers carry a 30-day Appeals window. A well-documented Offer with a complete Form 433-A(OIC) or 433-B(OIC) financial package moves faster than one returned for incompleteness. An Ohio AG compromise under R.C. § 131.02 typically runs four to nine months on a parallel track.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement / OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Ohio state collection follows a similar pattern: a TBOR-1 routes state contact, and a pending Ohio AG compromise or Payment Plan request pauses enforcement. The CCA halts municipal collection once a payment plan or written protest is on file.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $91 million in tax relief for clients across all 50 states.

Page last reviewed: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Ohio statute citation references the Ohio Revised Code maintained by the Ohio General Assembly. Every administrative authority links to its primary .gov source. Material changes to the law are reflected within 30 days of effective date.

Attorney Advertising. This page is provided by Victory Tax Lawyers, LLP for general informational purposes only. Nothing on this page constitutes legal advice, creates an attorney-client relationship, or substitutes for consultation with a licensed attorney about your specific tax matter. Prior results described or referenced do not guarantee a similar outcome. Each tax case turns on its individual facts, applicable law, and the discretion of the Internal Revenue Service, the Ohio Department of Taxation, the Central Collection Agency, the U.S. Tax Court, the Ohio Board of Tax Appeals, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the State of Ohio; where an Ohio state-court appearance or Ohio Board of Tax Appeals litigation is required, the firm associates with locally admitted counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

Authorities cited on this page

26 U.S.C. § 7122 — Federal Offer in Compromise
26 U.S.C. § 6159 — Installment Agreements
26 U.S.C. § 6321 — Federal Tax Lien
26 U.S.C. § 6325 — Lien Release and Discharge
26 U.S.C. § 6331 — Levy and Distraint
26 U.S.C. § 6343 — Release of Levy
26 U.S.C. § 6502 — Collection Statute Expiration
26 U.S.C. § 6213 — Tax Court Petition Window
26 U.S.C. § 6320 — CDP for Liens
26 U.S.C. § 6330 — CDP for Levies
26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
26 U.S.C. § 6672 — Trust Fund Recovery Penalty
26 U.S.C. § 6015 — Innocent Spouse Relief
26 U.S.C. § 7345 — Passport Revocation
26 U.S.C. § 83 — Property Transferred in Connection with Performance of Services (RSU vesting)
26 U.S.C. § 422 — Incentive Stock Options
26 U.S.C. § 1235 — Patent Sale Capital-Gain Treatment
26 U.S.C. § 199A — Qualified Business Income Deduction
26 U.S.C. § 56 — Alternative Minimum Tax adjustments (ISO bargain element)
26 U.S.C. § 38 — General business credit (environmental cleanup)
31 U.S.C. § 5321 — FBAR civil penalties
R.C. § 5747.02 — Ohio graduated personal income tax (0% to 3.5%)
R.C. § 5747.05 — Ohio non-resident athlete duty-day allocation
R.C. § 5747.07 — Ohio withholding-tax responsible-officer liability
R.C. § 5747.10 — Ohio federal-change reporting
R.C. § 5747.13 — Ohio Notice of Assessment and assessment statute of limitations
R.C. § 5747.15 — Ohio late-filing and late-payment penalty
R.C. Ch. 5751 — Ohio Commercial Activity Tax (5.75% on gross receipts)
R.C. § 5739.02 — Ohio state sales tax (5.75%)
R.C. § 5739.021 — Cuyahoga County permissive sales tax (2.25%)
R.C. § 5739.33 — Ohio sales-tax responsible-person liability
R.C. § 5741.02 — Ohio Use Tax
R.C. § 5703.05 — Ohio Tax Commissioner powers and TBOR-1 authority
R.C. § 5703.50 to 5703.56 — Ohio Taxpayers' Bill of Rights
R.C. Ch. 5717 — Ohio Board of Tax Appeals (60-day petition window)
R.C. § 5717.04 — Ohio Supreme Court review of Board of Tax Appeals decisions
R.C. Ch. 5748 — Ohio school-district income tax
R.C. Ch. 718 — Ohio uniform municipal income tax (H.B. 5 of 2014)
R.C. § 131.02 — Certification of state debts to the Ohio Attorney General
R.C. § 2329.07 — Ohio judgment-lien dormancy and revival
Cleveland Codified Ordinances Ch. 191 — Cleveland 2.5% municipal income tax